Singapore’s autonomous sanctions on Russia: lack of clarity will cause business uncertainty

On 28 February 2022, Singapore’s Minister for Foreign Affairs announced that Singapore would join other like-minded countries to impose sanctions and restrictions against Russia. This comes after Russia’s invasion of Ukraine and the failure of the United Nations Security Council’s resolution to condemn Russia’s aggression against Ukraine due to Russia’s veto.

On 5 March 2022, Singapore’s Ministry of Foreign Affairs (“MFA”) issued a statement that detailed the specific sanctions to be imposed on Russia. The two categories of sanctions – export control measures and financial measures – are set out in factsheets annexed to the statement. On 7 March 2022, Singapore Exchange Regulation (“SGX RegCo”) published “What SGX expects of issuers in respect of sanctions-related risks, subject or activity” (“Guidance”) setting out Singapore Exchange Securities Trading Limited’s (“SGX’s”) expectations of issuers, or any person or entity closely associated with the issuer listed on the SGX (“Issuers”), in respect of compliance with sanctions regimes.

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